“The electric power industry is committed to providing reliable, affordable and increasingly clean electricity to power the U.S. economy and to enhance the daily lives of all Americans. Our industry continues to lead the way in taking actions to reduce emissions. Nitrogen oxides and sulfur dioxide emissions from power plants have been reduced by almost 75 percent from 1990 levels, during a period when electricity use has grown by more than 40 percent. Additionally, utilities have reduced carbon dioxide emissions by 15 percent below 2005 levels as of the end of 2013. They also are investing more than $90 billion each year to transition to a cleaner generating fleet and to enhance the electric power grid to meet the needs of our 21st century economy.

“EEI’s comments submitted to EPA provide suggestions regarding many of the concerns that the electric power industry has with the guidelines as they have been proposed. It is critically important that EPA provides states with achievable emission reduction goals and compliance deadlines. The transition to a cleaner generating fleet requires a great deal of time, infrastructure development and planning that EPA has not allowed for in the proposed guidelines’ compliance schedule.

“The proposed guidelines’ inclusion of interim goals forces states to achieve much of the required reductions before 2020. There is not sufficient time between now and 2020 for utilities and states to develop, plan, design, and complete the infrastructure required to meet the interim goals as proposed. As a result, EPA’s approach would have a significant impact on electricity customers and the nation in terms of the cost and overall reliability of the electric system. Eliminating the interim goals would allow states to determine the most cost-effective actions and measures to achieve EPA’s 2030 goals.

“Our industry also has many concerns with the four building blocks in EPA’s proposed ‘best system of emission reduction’ and questions whether the state emission rate goals are achievable. The final guidelines should affirm the ability of the states to include a wide range of measures – both those identified by EPA in the guidelines and those not specifically included – in an approvable state compliance plan to reduce emissions.

“All zero-emission electric generation sources play a critical role in reducing GHG emissions. Our industry cannot achieve its GHG reduction goals without our existing nuclear fleet. It is essential that EPA also recognize the importance of electrification in reducing GHG emissions from all sectors of the economy.

“EEI will continue to work closely with our member companies and with states and other stakeholders throughout the rulemaking process to provide EPA with relevant information and data about the impact of these guidelines on our industry’s ability to provide reliable, affordable and increasingly clean electricity to all customers.”